2CAN030503, Supplemental to Amendment Request for Shutdown Cooling Automatic Closure Interlock Removal

Supplemental to Amendment Request for Shutdown Cooling Automatic Closure Interlock Removal

ML050750036
Person / Time
Site:	Arkansas Nuclear
Issue date:	03/08/2005
From:	James D Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2CAN030503
Download: ML050750036 (6)

Text

A-- EnterW Entergy Operations, Inc.

1448 S.R. 333 Russellville, AR 72802 Tel 479-8584888 2CAN030503 March 8, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

REFERENCES:

Supplemental to Amendment Request For Shutdown Cooling Automatic Closure Interlock Removal Arkansas Nuclear One, Unit 2 Docket No. 50-368 License No. NPF-6

1. Entergy letter to the NRC dated July 8, 2004, "Shutdown Cooling Automatic Closure Interlock Removal" (2CAN070401)

2.

Entergy letter to the NRC dated February 2, 2005, "Supplement to Amendment Request For Shutdown Cooling Automatic Closure Interlock Removal" (2CAN020503)

Dear Sir or Madam:

By letters (Reference I and 2), Entergy Operations, Inc. (Entergy) proposed a change to the Arkansas Nuclear One, Unit 2 (ANO-2) Technical Specifications (TSs) in support of removing the automatic closure interlock (ACI) associated with the Shutdown Cooling (SDC) system suction motor-operated valves.

Entergy was notified by your staff on March 8, 2005, of a request to reduce the maximum allowable setpoint for the SDC open permissive interlock (OPI) function from 445 to 400 psia.

Entergy has agreed to this request and has included a revised markup of the proposed OPI surveillance in Attachment 2. A discussion of this revision is included in Attachment 1.

The change in OPI setpoint is conservative in nature. The original no significant hazards consideration included in Reference 1 is not affected by any information contained in this supplemental letter. Furthermore, the commitments contained in Reference I remain unaltered.

If you have any questions or require additional information, please contact David Bice at 479-858-5338.

ago I

2CAN030503 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on March 8, 2005.

Sincerely, Dale E. James Acting Director, Nuclear Safety Assurance RLH/dbb Attachments:

1. Response to Request for Additional Information

2. Proposed Technical Specification Changes (mark-up) cc:

Dr. Bruce S. Mallett Regional Administrator U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector Arkansas Nuclear One P.O. Box 310 London, AR 72847 U. S. Nuclear Regulatory Commission Attn: Mr. Drew Holland MS 0-7 D1 Washington, DC 20555-0001 Mr. Bemard R. Bevill Director Division of Radiation Control and Emergency Management Arkansas Department of Health 4815 West Markham Street Little Rock, AR 72205 To 2CAN030503 Response to Request for Additional Information to 2CAN030503 Page 1 of 1 Response to Request for Additional Information Related to License Amendment In Support of Shutdown Cooling Automatic Closure Interlock Removal Question 1:

It appears that the proposed TS surveillance requirement 4.5.2. d. 1 for the open permissive function provides no margin to the LTOP relief setpoint. Please justify the reason for selecting this setpoint or propose a reduced setpoint as appropriate.

Response 1:

As a result of several telephone conversations with one or more members of the NRC staff, Entergy Operations, Inc. (Entergy) has agreed to reduce the Open Permissive Interlock (OPI) function setpoint to 400 psia. Although the previous proposal of 445 psia did not present a significant safety concern, Entergy agrees that choosing a setpoint below the Low Temperature Overpressure (LTOP) relief valve setpoints is appropriate. Attachment 2 provides a new markup of the affected Technical Specification (TS) page.

To 2CAN030503 Proposed Technical Specification Changes (mark-up)

e~

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the following valves are in the indicated positions with power to the valve operators removed:

Valve Number Valve Function Valve Position 2CV-51 01 HPSI Hot Leg Injection Isolation Closed 2CV-5102 HPSI Hot Leg Injection Isolation Closed 2BS26 RWT Return Line Open

b.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

c.

By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.)

is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

1. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and

2.

At least once daily of the areas affected within containment if containment has been entered that day, and during the final entry when CONTAINMENT INTEGRITY is established.

d.

At least once per 18 months by:

1. Verifying Shutdown Cooling System open Dermissivcautomatic isolation and interlock prevents the valves from being opened action of the shutdown cooling system from the Reactor Coolant System with a simulated or actual when the Reactor Coolant System pressure sianal!s abeve 2 400300 psia.

2.

A visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

e. At least once per 18 months, during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on SIAS and RAS test signals.

2.

Verifying that each of the following pumps start automatically upon receipt of a Safety Injection Actuation Test Signal:

a.

High-Pressure Safety Injection pump.

b.

Low-Pressure Safety Injection pump.

ARKANSAS - UNIT 2 3/4 5-4 Amendment No. 3Q,462,2&4,